Buttfield v. Stranahan

Background

An importer challenged an 1897 law that authorized the Treasury Department and a board of tea experts to create uniform samples and quality standards for teas. The importer said his shipments were pure and fit to drink, but government tea examiners and the Board of General Appraisers rejected the tea and started the statutory removal and destruction process. The dispute raised claims that Congress illegally delegated legislative power, that the importer had a vested right to import, and that destroying rejected tea without a judicial hearing denied due process. The law’s history shows Congress added the word “quality” to exclude the lowest grades and to protect consumers.

Reasoning

The Court considered whether Congress, under its foreign-commerce power, could set policy and leave technical standard-setting to an executive official. It held Congress validly established the policy to exclude inferior teas and lawfully entrusted the Secretary of the Treasury with implementing standards to carry out that policy. The decision explained that no one has a guaranteed right to import goods contrary to Congress’s rules, that the statute’s testing and reexamination procedures were proper, and that the absence of a prestandard-setting hearing did not amount to a denial of due process. The Court also found the statutory destruction provision acceptable because importers had notice and a reasonable statutory window to remove goods.

Real world impact

The ruling affirms the Government’s authority to exclude low-grade imported tea and to destroy shipments left uncleared after the statutory period. Importers must meet official standards or remove their goods within the set time. The Court did not decide whether officials acted in bad faith, and two Justices did not participate.